Scope: AI

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Recap: LinkedIn Live debate on the SRB ruling

Amazing turnout for our LinkedIn Live on the SRB ruling – here are the slides, and the replay is available. We tackled issues surrounding the fundamental concepts of the GDPR, the scope of obligations applicable to the use of pseudonymous data, even whether AI models involve the processing of personal data, and of course the […]

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What is the “combination” of data under the Digital Markets Act?

In law, the choice of words matters, and a given interpretation can mean the difference between a behaviour being permitted or prohibited. When some recently claimed that the Cologne Higher Regional Court might have misinterpreted one of the European Union’s newer data-related acts, the Digital Markets Act (DMA for short), the challenge to the judges’ […]

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AI models and the notion of “personal data”: a relativistic approach

While I disagree with his conclusions, do read the post of Damien Desfontaines re the BfDI’s public consultation on personal data in AI models. Pity that it ends on 31 August, with the EU Court of Justice’s SRB judgment coming out on 4 September. I hope the BfDI takes a relativistic approach to the notion […]

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Why businesses cannot afford to dismiss the corporate risk of deepfakes

Scarily powerful – don’t dismiss the risk of deep fakes for your company. With now tools like Deep Live Cam (“real time face swap and one-click video deepfake with only a single image”) making the rounds, it is imperative for you to educate *everyone* in your organisation about good reflexes regarding both cybersecurity and AI. […]

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Good & bad in judgment on Meta AI training & personal data (legitimate interests, sensitive data) + new French & German guidance

Does training of AI systems involve the processing of personal data, and is it permitted under the GDPR? These were the two fundamental questions that I have already looked into in two previous articles: On the date of that second article, the Cologne Higher Regional Court (the Oberlandesgericht Köln – the Cologne HRC) delivered a […]

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AI Agents – When agency and subordination go hand in hand

This is an article that I wrote in the context of a Chatham House rules roundtable on questions to be tackled more extensively in the future regarding the interaction between AI systems & data protection. This particular one relates to AI agents and the notion of authority, notably as regards (i) the user’s perspective (subordination?), […]

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Challenging technical assumptions in data protection enforcement

Not a “what ABC taught me about privacy” thing, but a man held on for dear life to the seat in front of him as the plane banked (normally) on my flight back from a great conference in Vilnius. It did bring me back to what I had been telling the hundreds of attendees to […]

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A curious settlement by the Belgian DPA over minor structural violations

Amusing settlement decision by the Belgian DPA published yesterday: 500 EUR & 250 EUR respectively, plus adaptations to policies and procedures, so that when people book a table in a given restaurant by phone their data isn’t included automatically in a third-party table booking system and then used to send commercial e-mails. The lesson? If […]

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Singapore’s new AI fairness toolkit highlights global governance trends

Today’s release of an artificialintelligence fairness toolkit (Veritas Toolkit v2.0) by the Monetary Authority of Singapore is an occasion to recall that there is no plug-and-play tool for everyone – but toolkits can be a useful source of inspiration. Released under an Apache 2.0 open source licence, the diagnosis tool (in Python) and assessment tool […]

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About AI training & legitimate interest as a GDPR legal ground

The Irish Data Protection Commission’s statement of 21 May 2025 “on Meta AI” (just like the judgment coming today in a German court case) provides a great excuse to talk briefly about GDPR legal grounds & AI model training, while I continue to work on the next part of my Better Regulation series (that next […]

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